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6 Reasons to Reject the Tondu Proposal

August 25, 2005
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By Joseph Miller

In making a decision about the Tondu proposal, we’re really making a number of broad and far-reaching decisions. The following are just six of those decisions.

1. Our first decision is about investment.

Should one billion dollars be invested to produce 550 megawatts of electricity through a commercially unproven technology (www.mlui.org/print.asp?fileid=16737), or is it better that this money remain available for investment in proven technologies that save electricity through energy efficiency, and produce electricity through renewables (e.g., wind)? Extensive evidence (e.g., Repowering The Midwest at www.repowermidwest.org , Becoming An Energy Star State at www.citact.org/energystar.html) suggests that energy efficiency and renewable energy technologies are the way to go.

2. Our second decision is about the health of humans and the ecosystem.

The Tondu plant will be fueled in part by coal. We all know about the dangers of coal throughout the cycle of mining -- end use -- emission of toxic pollutants and global warming gases. Does it make sense to further endanger present and future generations and the ecosystem when safe, proven energy efficiency and renewable energy technologies are available and can be further developed to create our electricity?

3. Our third decision is about petroleum coke.

The Tondu plant won't only be fueled by coal. More specifically, Tondu asserts that "as currently proposed, the project will use a blend of coal and petroleum coke as feedstock [and] the plant will use approximately 2 millions tons of feedstock per year to be delivered by rail." (www.tonducorp.com/crossroads.htm) Petroleum coke is a residue of the oil refining process that is exempted from classification as hazardous waste when used as fuel in gasification plants. Petroleum coke also has a number of qualities (e.g., high heating value, increasing supply, declining prices) that make its use as fuel increasingly likely. (www.worldenergy.org/wec-geis/publications/default/tech_papers/17th_congress/1_2_26.asp) An article entitled Proposed Petroleum Coke Power Plant Sounds Alarm, reports that in "June of 2004, the Ontario Ministry of Environment announced that the US-based Synfuel’s power plant proposal would be required to perform an Environmental Assessment under Ontario’s Environmental Assessment Act. Synfuel's plans have grown to include three new [Minnesota] power plants on or near Lake Superior; two near Thunder Bay, and one about an hour north in Red Rock. While the new gasification technology proposed is said to produce far less air pollution, the proposed fuel­a refinery by-product known as petroleum coke­has raised red flags with environmentalists. US facilities using this fuel are being watched closely by the US EPA. One site in Los Angeles is under an order for cleanup from leachate contamination and EPA is working on a nationwide rule for the fuel." (www.glhabitat.org/news/glnews424.html)

Several questions arise.

4. Our fourth decision is about other forms of hazardous waste and disincentives.

As described above, Tondu says "as currently proposed, the project will use a blend of coal and petroleum coke" as fuels for the plant. The question arises -- will other forms of hazardous waste be added to this "blend?" Is that the intent of the phrase "as currently proposed" in the Tondu statement?

A March, 2002 article entitled Hazardous Wastes Could Become New Fuel notes that the "U.S. Environmental Protection Agency (EPA) is proposing … [to] exempt some byproducts of petroleum refining and perhaps other industries from hazardous waste regulations such as the Resource Conservation and Recovery Act (RCRA). The materials would be processed, along with fossil fuels such as coal, petroleum, coke and even municipal solid waste and sewage sludge, to produce a synthetic gas. The EPA estimates that from the petroleum refining industry alone, up to seven to 10 million tons of hazardous byproducts now managed under the Resource Conservation and Recovery Act (RCRA) could be transferred to gasification systems." (www.enviroalternatives.com/hazardous.html)

If the proposed plant is built, will its "permits" allow it to be fueled by any type of hazardous waste byproduct exempted from RCRA regulations by the EPA?

R. G. Tondu's statement in the August, 2005 SNL Financial article may be predictive: " 'We are designing for the maximum flexibility possible' in terms of fuels." (www.snl.com/interactivex/article.aspx?CdId=A-2112423-13675)

Additional questions: Won't using different types of hazardous wastes as fuel affect the plant's emissions and reliability? Will increasing quantities of such wastes be coming into St. Joseph County and New Carlisle? If yes, won't transportation accidents involving hazardous wastes become more likely? If gasification plants become a ready route to dispose of hazardous wastes and the liability associated with such wastes, isn't this a disincentive to industry to create cleaner production processes, processes that produce fewer toxics and use less of our resources to begin with?

5. Our fifth decision is about the large quantities of carbon dioxide that will be released from the proposed plant, and their contribution to global warming and all the perils related to such warming.

Advocates of Integrated Gasification Combined Cycle (IGCC) plants such as the proposed Tondu plant note that such plants will not be effective in controlling carbon dioxide emissions until commercially viable carbon sequestration technologies are available.

Such technologies won't be available for 15 years or more, if ever. For example, to "effectively reduce carbon dioxide emissions, the coal gasification would need to be linked to carbon sequestration technology -- storing carbon dioxide so it doesn't enter the atmosphere -- that won't be viable for 15 years, said Dan Riedinger, a spokesman for the Edison Electric Institute, and association of utilities that produce more than 70 percent of the nation's electric power." ( www.post-gazette.com/pg/05167/522393.stm )

Sequestration also adds considerably to the cost of the electricity produced by a gasification plant. "According to Electric Power Research Institute (EPRI), the utility industry's research and development arm …. carbon sequestration potentially adds 30 percent to the cost of electricity in a coal gasification plant." (www.commodities-now.com/content/market-news/market-news-2005033193227.php)

When R. G. Tondu made his presentation to The County Council of St. Joseph County on Thursday, August 18, 2005, he indicated that if the proposed plant was built, it would be "carbon capture ready. Given that sequestration technology won't be available for at least 15 years and adds up to 30% to the cost of electricity, and given the connection between releases of carbon dioxide and global warming, we have yet another reason to reject the Tondu proposal, and embrace investment in energy efficiency and renewable energy technologies.

6. Perhaps we should multiply the weight of all the above decisions by two, because R. G. Tondu is on record as saying "the Crossroads site has enough space for a second 550 megawatt unit." (www.snl.com/interactivex/article.aspx?CdId=A-2112423-13675)

Joseph Miller is a resident of Mishawaka, IN, and Chair of the Department of Psychology at Saint Mary's College in Notre Dame, IN.

St. Joe Valley Greens, South Bend, IN